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Kozusko Harris Duncan | USA | 23 Sep 2021

Court upholds higher IRS penalty on late filing of Forms 3520 and 3520-A

The estate of a deceased US taxpayer recently lost its argument that the Internal Revenue Service (IRS) should have assessed only the 5% penalty levied on US owners who fail to ensure that their foreign trust files an annual return in a timely manner. The IRS assessed a penalty because both Form 3520, Annual Return to Report Transactions with Foreign Trusts, and Form 3520-A, Annual......
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Kozusko Harris Duncan | USA | 2 Sep 2021

Changing times: tax and reporting requirements for US citizens and Green Card holders moving abroad

For various reasons, some US citizens and Green Card holders are considering living abroad. How tax professionals and trust officers worldwide advise these individuals depends on their objectives. Does the individual want to live in another country for a limited number of years or to change domicile and resettle permanently? Will the individual be working abroad or living off savings and......
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Kozusko Harris Duncan | USA | 27 Mar 2019

US reporting: requesting IRS filing extensions

It is important for trustees of foreign trusts not to miss US tax filing deadlines or, if unable to file by the due date, to submit a request for an extension to file. Careful attention should be paid to where and how to submit the request, as procedures are not necessarily the same for all returns. This article sets out the various requirements that must be met by trustees of foreign trusts.
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Thorsteinssons LLP | Canada, USA | 22 Feb 2019

Continued erosion of taxpayer privacy

The Canadian Broadcasting Corporation recently reported that the Canada Revenue Agency has transferred more than 1.6 million Canadian banking records to the US Internal Revenue Service since the intergovernmental agreement for the enhanced exchange of tax information under the Canada-US Tax Convention was entered into in 2014. The agreement provides lengthy and detailed rules with respect to......
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McDermott Will & Emery | USA | 4 Jan 2019

Call for compliance: cryptocurrency may be subject to US tax

US taxpayers are generally taxable on income earned worldwide, regardless of the manner in which that income is paid (eg, currency (foreign or domestic) or property (tangible, intangible or virtual)). Therefore, if cryptocurrency has been bought, sold or exchanged, those transactions could be subject to federal tax. If the cryptocurrency is held offshore, a number of offshore reporting......
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Kozusko Harris Duncan | USA | 3 Jan 2019

US reporting checklist for foreign trusts

Trusts classified as foreign for US tax purposes, whether established under the law of a US state or of an offshore jurisdiction, must review whether they have any US tax or information reporting filings to make in 2019 with regard to income earned and distributions made in 2018. This article provides trust officers and family advisers with a summary checklist.
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Kozusko Harris Duncan | USA | 20 Sep 2018

Tax planning for US equities owned in a non-US trust structure

Keeping in mind US tax basis and estate tax issues while establishing and maintaining a succession planning structure can protect the estate of a non-US settlor from US estate tax and prove beneficial after the settlor's death where a branch of the family moves to the United States or a family member marries a US citizen. Recent changes to the US Tax Code have prompted some US tax advisers to......
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Thorsteinssons LLP | Canada | 7 Sep 2018

Cryptocurrency taxation: what business leaders need to know

In these heady days of cryptocurrency investment, the market can seem like a gold rush – offering promise, but at the expense of predictability. Cryptocurrency taxation is no different. Increasing scrutiny from all types of regulator, including the tax authorities, seems inevitable for the sector. While this may diminish potential profits when compared to the early days of cryptocurrencies,......
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Cliffe Dekker Hofmeyr | South Africa, USA | 25 May 2018

SARS speaks up: clarity provided on taxation of cryptocurrencies

The South African Revenue Service (SARS) recently announced that it will continue to apply normal income tax rules to cryptocurrencies and expects affected taxpayers to declare cryptocurrency gains or losses as part of their taxable income. Due to the growing popularity of cryptocurrencies in South Africa and the absence of legislation concerning their taxation and regulation, SARS's decision......
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Kozusko Harris Duncan | USA | 24 May 2018

Establishing 'foreign' trusts in the United States

Trusts remain a flexible succession planning tool for families wishing to pass wealth to future generations in a responsible manner and can include philanthropic goals. The wealth-creating settlor wants to establish such a trust in a jurisdiction with well-established trust laws, a stable business environment, responsive and efficient trust officers and clearly stated comprehensive annual......
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